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Pre-Residency Planning for Your Client’s Trust

Domestication in the international context.

Trust domestication has become increasingly common for global family trust structures. Whenever U.S. beneficiaries or U.S. settlors are in the mix (including non-U.S. settlors who later become U.S. persons), trust domestication can be critical to avoiding punitive tax rules and compliance headaches. For many foreign grantor trust structures with U.S. beneficiaries,1 this is the last stage of the foreign settlor’s2 succession plan, to be implemented after the settlor’s


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